O'Connor, J.T.C.C.:— This appeal was heard in Ottawa, Ontario on April 15, 1994 pursuant to the informal procedure of this Court. The only issue in this case is whether in his 1991 taxation year the appellant is entitled to deduct room and

Taylor, J.T.C.C. (orally):— Well I think it is obvious that I am neither a soothsayer, or Solomon, and there is no logical, rational or reasonable way to arrive at a conclusion in this case which could be statistically and arithmetically

Kempo, J.T.C.C.:— These general procedure appeals concern the appellant’s 1987 and 1988 taxation years ending January 31, 1987 and January 31, 1988, respectively.

Beaubier, J.T.C.C.:—This matter was heard in Toronto, Ontario on March 22 and 23, 1994. It is an appeal pursuant to the General Procedure of this Court. The appellant ("Antrex") called as witnesses Antonio Montemarano, its president and director, and Thomas Hall, C.A.,

Teskey, J.T.C.C.:— The appellant appeals its assessment of income tax for its fiscal year ending December 31, 1982.

Mogan, J.T.C.C.:— The appeals of Moffat v. The Queen (court file 92-1286), and 398827 Ontario Ltd. v. M.N.R. (court file 90-1253), were heard together on common evidence. In these reasons for

Hamlyn, J.T.C.C.:—The essence of these appeals lies with the taxpayer’s disagreement with the fair market value determined by Revenue Canada on real properties transferred, as well as, in particular whether the appellant had a beneficial interest in two of the